ML17284A446

Submits Clarification of Approved Fire Protection Program Per 880610 Exit Meeting,Covering Plant Design,Door Openings, Fire Barriers,Fire Dampers & Doors & Safe Shutdown Capability

ML17284A446
Person / Time
Site:	Columbia
Issue date:	07/26/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Knighton G NRC
References
GO2-88-163, TAC-63528, NUDOCS 8808030079
Download: ML17284A446 (9)

Text

ACCELERATED DlSTRlBUTION DEMONSTR+TlON SYSTEM REGULAT INFORMATION DZSTRZBUTZOA~STEM (RIDE)

ACCESSION NBR:8808030079 DOC.DATE: 88/07/26 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION SCRENSEN,G.C. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION KNIGHTONFG. NRC No Detailed Affiliation Given

SUBJECT:

Discusses 880610 meeting re fire protection insp.

DISTRIBUTION CODE: AOOSD COPIES RECEIVED:LTR OR/Licensing Submittal: Fire Protection

/ ENCL + SIZE'ITLE:

I NOTES: D RECIPIENT COPIES RECIPIENT COPIES S ID CODE/NAME PD5 LA SAMWORTHFR LTTR ENCL 1

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1 ID CODE/NAME PD5 PD LTTR ENCL 5 5 j A

INTERNAL: ACRS 3 3 ARM/DAF/LFMB 1 0 NRR WERMEILFJ 1 0 NRR/DEST/ADS 7E 1 1 NRR/DEST/PSB 8D 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 -E~XIK~ 0 1 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 S

h TOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL 16

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 Docket No. 50-397 G02-88-163 July 26, 1988 Nr . George B. Knighton U. S. Nuclear Regulatory Commission P1-137 1<ashington, D. C. 20555

Subject:

NUCLEAR PLANT NO. 2 OPERATING LICENSE NPF-21 APPROVED FIRE PROTECTION PROGRAM

References:

( 1) Letter, GC Sorensen to NRC, Fire Protection Program, dated January 29, 1987 (G02-87-034)

(2) Letter, EG Adensam (NRC) to GC Sorensen, same subject, dated February 5, 1987 During the exit meeting on June 10, 1988 for the fire protection inspection at HNP-2, there was considerable discussion concerning the "approved Fire Protection Program" for 'l<NP-2 and actions which could be taken by the Supply System under. that program and our License Condition 2.C ( 14). Based on that discussion, it appears that further clarification is required as to how License Condition 2.C (14) is to be applied. License Condition 2.C (14) states that:

"The licensee shall maintain in effect all provisions of the approved Fire Protection Program."

In response to direction provided by NRC staff during a fire protection exit meeting with members of NRC and Region V at Supply System offices on January 15, 1987, the Supply System transmitted Reference 1 which outlined the "approved Fire Protection Program." Additionally, prior to submittal, the program was presented to and discussed in detai 1 with the staff during meetings on January 20 and 21, 1987 in Bethesda. Reference 2 provided NRC acknowledgement that the attachment to Reference 1, for purposes of License Condition 2.C ( 14) "will be considered your approved Fire Protection Program." This approval was contingent on the timely submittal by the Supply System of a license amendment request pursuant to PM'ok the guidance of Generic Letter 86-10. This license amendment request was submitted in a timely manner on February 10, 1987 and is presently under staff review.

8808030079 ADOCH, 05000397 88072'DR

G. Kni ghton Fire Protection gh Page 2 In accordance with the agreement at the January 1987 meeting, as documented in Reference 1, the Supply System has not altered any provision of the approved Fire Protection Program without pr ior NRC staff approval. As noted in Reference 1, we have made changes in the facility or procedures as described in the FSAR pursuant to 10CFR50.59. These changes did not alter the approved program, nor did they involve any of the situations evaluated under 10CFR50.59, which would have required prior staff approval.

It should be noted that clarification is required in two areas of the program description provided with Reference l.

(1) Under Paragraph III.A. "Plant Design," it is stated that "door openings in required fire barriers are protected with listed 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated doors." The sentence should be amended as follows: "Door openings in required fire barriers are protected with listed 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated doors except for locations where a lesser rating is used and that use has been previously recognized and approved by the 'staff and noted in the FSAR." This same revision applies'o Paragraph V.A. "Control Room."

There are areas where fire dampers and doors having less than a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating are provided. However, the fire hazards analysis shows that a lesser rating is acceptable. The above clarification is a par t of the plant design which was reviewed and approved by the NRC.

No change to the program is implied.

(2) Paragraph III.B "Safe Shutdown Capability," the listing of systems used for safe shutdown for purposes of fire protection, should be revised as follows:

a) Three of seven automatic .

Should be: "Six of seven automatic .

b) "Three ADS valves controlled from the Alternate Remote Shutdown Panel."

Should be: "Three ADS valves controlled from the Alternate Remote Shutdown Panel and three safety relief valves controlled from the Remote Shutdown Panel."

These changes were made at NRC direction and therefore had NRC approval prior to implementation. A marked up copy of the affected pages is enclosed with this letter.

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G Knighton Fire Protection Page 3 FSAR Amendment 37 (September 22, 1986) described the implementation of the WNP-2 Fire Protection Program. Changes to this description were made "

in FSAR Amendment 38 (August 26, 1987), and further changes will be provided in Amendment 39 (scheduled for submittal in September 1988).

These changes in the FSAR description do not alter any provisions of the approved Fire Protection Program as provided to the NRC (Reference 1).

As requested in 'Reference 2, the Supply System submitted (February 10, 1987) a request to amend the WNP-2 license to incorporate the "standard license condition" contained in Generic Letter 86-10. NRC approval of this amendment request will permit the Supply System to make changes to the a roved rogram 'if those cHanges would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. In the meanwhile, pending NRC approval of the Generic Letter 86-10 license amendment, we will not make changes to the approved fire protection program without prior NRC approval.

As noted, we do not consider the changes which have been made to be programmatic changes. If further clarification is necessary, we would be pleased to meet with you and other staff members as necessary to resolve any outstanding questions.

We were pleased with the results achieved during the June 6-10 fire protection inspection, and trust that the few remaining open items will soon be closed.

Should you have" questions, please contact Nr. Alan Hosier, WNP-2 Licensing t1anager at (509) 377-2327.

Very truly yours G. C. S rensen, Nanag r Regulat ry Programs cc: NS Reynolds/BCP8R RB Samworth/NRC JO Bradfute/NRC JB Martin/RV CB Ramsey/RV AD Johnson/RV Document Control Desk NRC Resident Inspector

A trained and equipped 5-member Fire Brigade is provided for each shift. Fire Brigade drills are conducted at regular intervals not to exceed three months, with a drill including the local fire department at least every 12 months." The Fire Brigade and Fire Brigade Training shall comply with the criteria outlined in 10 C.F.R. 50, Appendix R, Sections III.H and III.I.

The plant Fire Brigade is trained to be self-sufficient. However, backup firefighting response is provided by agreement with a local fire department. Backup responders are oriented regarding plant physical layout and special hazards.'.

gual it Assurance Proar am The quality assurance program is under the management of the Director of Licensing and Assurance, who reooris directly to the Managing Director.

The quality assurance organization formulates a fire protection gA program that is acceptable to the Plant Manager and verifies the effectiveness of the fire protection related activities through suitable reviews, surveill ances and audits.

III. PLANT REQUIREMENTS A. ~Pt D Redundant divisions of safe shutdown systems (including cabling) comply with the seoaration requirements of Section III.G of Aopendix R to 10 C.F.R. Part 50 so that both trains are not subject to damage from a single fire.

Openings through required fire barriers for pipe, conduit, and cable trays are sealed with tested and approved 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire seals or justification for a lesser seal is provided that is comparable to that documented in the FSAR and previously approved by the NRC Staff. The inside of conduits are sealed using seals of acceptably tested configura-tions or which have been found acceptable by analysis to prevent the nassage of smoke and hot gases across bar riers.

Penetration openings for ventilation systems are provided with listed fire dampers having a rating equivalent to that required of the barrier, except for locations where justification is provided for a lesser rating which is comparable to that documented in the FSAR and previously approved by the Staff.

Door openings in required fire barriers are protected with listed 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated doors Openings that are larger than those normally found or requiring pecial application are provided with doors of equivalent rating a noted by the manufacturer. Fire doors are verified operable in acco dance with MNP-2 Technical Specifications.

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Emergency lights are provided in areas that must be accessed (ingress and egress) for safe shutdown. Fixed emergency communications indepen-dent of the normal plant communication system are located at preselected stations. A portable communications system is provided for the Fire Brigade.

I Plant design used non-combustible materials to the extent possible for walls, roofs, ceilings, floors, etc. A surface treatment may be applied where it meets the provisions of Generic Letter 86-10, Enclosure I at p. 15, answer 3.5.2, e.g.,-control room wall paneling with fire retardant plastic laminate (see FSAR Amendment 33 at p.

F.2-107). Transformers are dry type or cooled with a noncombustible liquid in areas that contain safe shutdown equipment.

B. Safe Shutdown Ca abilit Fire protection is provided for, structures, systems, and components important to safe shutdown of the plant during and following a fire.

The protection limits fire damage so that one train of systems necessary to achieve and maintain cold shutdown conditions is available from either the Main Control Room or the Remote and Alternate Remote Shutdown panels, the SM-8 Switchgear, and the DG-2 Control Panel.

For the purposes of fire protection, the systems used for safe shutdown are as follows:

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1) -Three of seven Automatic Depressurization System (ADS) Valves controlled from the Main Control Room. Divisionalized control of ADS Valves is described in FSAR Section 7.3.1

2) Three ADS Valves controlled from the Alternate Remote Shutdown Panel a~d doree SP'YS C gg~fl~d'~.P< ~~,+ 5$ ~ga4av Pane/

3) Residual Heat Removal System (RHRS)

4) Standby Service Hater System (SSHS)

5) HVAC System

6) Electrical Distribution System (including the diesel generators)

7) Controls and instrumentation required f'r operation located on Main Control Room panels, Remote and Alternate Remote Shutdown panels, SM-8 switchgear, and the DG-2 panel for the above systems.

The Supply System has taken actions to assure the availability of at least one train of the'se systems in the event of a fire in any one fire area. The divisions available for each fire area are set forth in Table 1.

C. Safe'Shutdown Criteria Safe shutdown systems installed to ensure postfire shutdown capability need not be designed to meet seismic Category I criteria, single failure criteria, or other Design Basis Accident criteria, except where required due to interface with or impact on existing safety systems.

In addition, credible spurious signals due to fire damage will not prevent safe shutdown.

'f The safe shutdown equipment and systems for each fire area are independent allied circuits (i.e., circuits other than safe shutdown circuits whose failure may result in loss of safe shutdown capability) in the fire area such that hot shorts, open circuits, or shorts to ground in the allied circuits will not prevent operation of the safe shutdown equipment.

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C. Halon Su ression S stems Halon 1301 fire extinguishing systems are provided in the Main Control Room under the floor raceway system (PGCC) and meet NFPA 12A or an acceptable deviation from the code shall be available. Preventative maintenance and testing of the systems are performed in accordance with WNP-2 Technical Soecifications. E D. Portable Extin uishers Fire extinguishers are provided which meet NFPA 10 or an acceptable deviation from the code shall be available. Testing and maintenance are performed in accordance with the WNP-2 Technical Soecifications.

Y. REQUIREMENTS FOR SPECIFIC PLANT AREAS ZYceP g +p /uc~4~/~-y/.

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A. Control Room 0 wgb( caAo t pent'/-

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+ IH + f"X gZ The Main Control Room is separated from other reas of the plant by barriers having minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Peripheral rooms in the Main Control Room (shift manager offices, pipe space, rest room and kitchen) are protected with an automatic sprinkler system and separated from the Control Room by noncombustible construction. The Control Room is provided with fire extinguishers and fi re detection.

Breathing apparatus for Main Control Room operators is available in the Control Room.

B. Cabl e Soreadin Room The primary fire suppression system in:the cable spreading room is preaction with directional spray heads. Hose stations and portable extinguishers are located immediately outside the room; early warning smoke detection is provided. A 20 foot area of no intervening combustibles is included.

C. Switch ear Rooms Switchgear rooms containing safe shutdown equipment are separated from the remainder of the plant by barriers with a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Redundant switchgear divisions are separated from each other by barriers with a 3-hour fire rating. Detection is provided and wi 11 alarm in the Main Control Room. Fire hose stations and portable fire extinguishers are provided.

D. Remote and Alternate Remote Shutdown Rooms Rooms containing shutdown equipment providing Alternative Shutdown capa-bility are separated from each other and the Control Room by barriers having a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Panels providing Alternative Shutdown capability are electrically isolated from the Control Room or protected so that a fire in the Control Room will not effect shutdown capability from the remote area. These rooms are provided with automatic fire detection that alarms in the Control Room. Portable extinguishers and manual hose stations are provided.